Guide
Cosmetics on Amazon: MoCRA’s US agent is not the food-facility agent
A foreign cosmetics plant names a US agent on its MoCRA facility registration. A foreign food or supplement plant names one on its food-facility registration. They are different statutes, different portals, and often different emails.
Updated 2026-08-24
The short answer
MoCRA added section 607 of the FD&C Act. A foreign cosmetic facility’s registration must include the United States agent’s name and phone number, and email if available. FDA’s cosmetics guidance says that agent resides in the US or maintains a US place of business and is physically present, and should not be a mailbox or answering service.
Food and dietary supplements sit in 21 CFR part 1, subpart H, and are filed in FURLS. Cosmetics under MoCRA are filed in Cosmetics Direct. Naming an agent in one system does not populate the other.
Who is a cosmetics facility
MoCRA’s facility is an establishment, including an establishment of an importer, that manufactures or processes cosmetic products distributed in the United States. That is a narrower activity list than food-facility “manufacture, process, pack or hold.”
A warehouse that only holds sealed cosmetic units is not automatically a MoCRA manufacturing facility. A foreign filling plant that makes the cream is. Amazon FBA does not replace that plant’s MoCRA US agent.
What Amazon sellers with both a cream and a gummy are holding
The gummy, if it is a dietary supplement, is food. The cream is a cosmetic unless it is also a drug. Two product categories can mean two facilities, two programmes, two agents — or one firm named on both, with two confirmations.
FDA does not issue a certificate for MoCRA registration or listing, and says those filings are not an approval programme or a promotional tool. Putting “FDA registered cosmetic” on the Amazon image does not complete either filing.
Fees, because the two programmes are sold as one bundle too often
FDA charges no fee for cosmetic facility registration or product listing, and no fee for food-facility registration. What you pay a firm is a service fee.
Our current US-agent year is $299. MoCRA facility registration including one listing is $549. The MoCRA package on the pricing page is $999. Food-facility work is priced separately. See also what MoCRA actually requires of Amazon cosmetics sellers.
Common questions
I already have a food US agent. Does that cover lipstick?
Not automatically. Lipstick is not registered on the food-facility form. The cosmetics plant needs its MoCRA agent named in Cosmetics Direct.
Can the same California office be both?
Yes, if it agrees in both programmes and is physically present. Ask for both designations in writing.
Does MoCRA use FURLS?
No. FDA’s cosmetics portal is Cosmetics Direct. Food facilities use FURLS at access.fda.gov.
Is a US agent required for a US cosmetics lab?
MoCRA requires the agent with respect to a foreign facility. A domestic cosmetics facility registers without that foreign-agent field.
Will this stop Amazon asking for an FEI?
MoCRA uses the FEI as the facility registration number. An agent is not an FEI. Give Amazon the identifier that belongs to the programme they are asking about.
Sources
- FDA, Guidance for Industry: Registration and Listing of Cosmetic Product Facilities and Products — foreign cosmetic facility US agent; mailbox or answering service should not qualify; registration contents under section 607 — fda.gov
- FDA, Registration and Listing of Cosmetic Product Facilities and Products — manufacturers and processors register; renew every two years; Cosmetics Direct — fda.gov
- 21 CFR 1.227 — food-facility US agent, including dietary supplements as food — ecfr.gov
This guide is general information about MoCRA versus food-facility US agents for Amazon sellers, not legal advice, and it does not create a client relationship. Whether a product is a cosmetic, a drug or a supplement depends on intended use.
Want this handled?